IR 05000245/1986012

Safety Insp Repts 50-245/86-12,50-336/86-12 & 50-423/86-23 on 860707-11.No Violations Noted.Major Areas Inspected: Radiation Insp Program Including Personnel Training & Qualifications & Internal Exposure Controls

ML20204H831
Person / Time
Site:	Millstone
Issue date:	08/01/1986
From:	Kaminski M, Shanbaky M, Weadock A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20204H824	List: IR 05000245/1986012 ML20204H819
References
50-245-86-12, 50-336-86-12, 50-423-86-23, NUDOCS 8608080214
Download: ML20204H831 (11)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

50-245/86-12 50-336/86-12 Report No. 50-423/86-23 50-245 50-336 Docket N DPR-21 DPR-65 License No. NPF-49 Priority -

Category C Licensee: Northeast Nuclear Energy Company P.O. Box 270 Hartford, Connecticut 06101 Facility Name: Millstone Nuclear Generating Station, Units 1, 2 and 3 Inspection At: Waterford, Connecticut Inspection Conducted: July 7-11, 1986 Inspectors: Mbd ftA.Readock,RadiationSpecialist

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'nt 14numdo shIsco M. Kaminski, Radiation Specialist ' d' ate

/s Approved by: M S/

M. ShanbakyT' Chi f, Fa6Pfities h/

date Radiation Protection Section Inspection Summary: Inspection on July 7-11, 1986 (Combined Inspection Report Numbers 50-245/86-12, 50-336/86-12, 50-423/86-23).

Areas Inspected: Routine, unannounced safety inspection to review the Radia-tion Protection program. Areas reviewed included: Personnel Training and

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Qualifications, Internal and External Exposure Control, Surveys, Audits, ALARA, and Status of Previously Identified Item Results: Within the areas inspected, no violations were identifie pgg8080214860804 G ADOCK 05000245 PDR l

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DETAILS 1.0 Persons Contacted M. Brennan Radiation Protection Supervisor, Unit 1

• B. Granados Health Physics Supervisor J. Kangley Radiological Services Supervisor

• J. Kelley Station Services Superintendent E. Laine Radiation Protection, Supervisor, Unit 2 W. Romberg Station Superintendent P. Simmons Radiological Protection Support Supervisor

• Denotes those individuals attending the exit interview on July 11, 19C Other licensee employees were also contacted during the course of this inspectio .0 Purpose The purpose of this routine safety inspection was to review the implemen-tation of the licensee's Radiation Protection Program. All units were operational during this inspection. The following areas were reviewed:

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status of previously identified items;

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personnel training and qualifications;

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external exposure control;

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internal exposure control;

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posting and labeling of radiological areas;

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audits of radiological activities; and,

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ALAR .0 Status of Previously Identified Items 3.1 (Closed) Unresolved item 245/84-13-01: Licensee to improve selection criteria for contractor HP technicians. The licensee has made ap-proved revisions to their contractor technician selection criteria which requires an evaluation of and imposes limits on previous work experienc Details are provide in section .2 (Closed) Follow-Up Item 245/85-23-01, 336/85-28-01, 423/85-47-01:

Evaluate total uncertainty associated with the licensee's method of TLD calibration. The inspector viewed the licensee's shielded cali-brator, the R-chamber and electrometer used for TLD irradiations, and reviewed licensee Memo NEE-80-RA-524, " Reply to Assignment A-18",

outlining NUSCO Dosimetry Laboratory TLD irradiation methodolog Licensee use of their current R-chamber during TLD irradiations involves an acceptable level of uncertainty (approximately i 3%).

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3.3 (Closed) Unresolved Item 245/85-23-02, 336/85-28-02, 423/85-47-02:

Review required QA discrepancy investigation reports for spiked TLD's. Details in section .4 (Closed) Follow-up Item 245/85-23-03, 336/85-28-03, 423/85-47-03:

Review portable ion-chamber data for response to high energy gammas and fast neutrons. The licensee was unable to locate the test data generated during the original performance of this test. The in-spector reviewed the results obtained during the re performance of this test in January 17, 198 No discrepancies were noted. This test is performed to show neutron insensitivity of pocket ion-cham-bers and is only required by the licensee's procedure to be performed during the initial acceptance check of a dosimete .5 (Closed) Follow-up Item 245/85-23-05, 336/85-28-05, 423/85-47-05:

Review the derivation of the minimum reportable dose in the algorithm for assignment of personnel dose. The licensee has modified their methodology for the formulation of minimum reportable dose to increase sensitivity and conservatis .6 (Closed) Violation 245/85-28-01: Failure to follow requirements on RW The licensee has satisfactorily completed the corrective actions described in their response to this violation, details are provided in section .7 (Closed) Follow-up Item 245/85-28-02: Evaluate scope of Radiation Work Permits (RWPs) to determine if generic problem exists in making scope too broa NRC review of a number of recently issued RWPs indicated scope is acceptable; details in section .8 (Closed) Unresolved Item 245/85-28-03: Review licensee corrective actions in contamination incident on November 4, 1985. During this incident two contaminated workers exited the controlled area, decon-taminated themselves, and left the site without notifying Health Physics (HP). The inspector reviewed the licensee's corrective ac-tions, which included counseling of the workers as to appropriate actions to take when contaminated and briefing of all HP technicians as to the details of the incident and the potential for such occur-rences during shift turnove Licensee corrective and follow-up actions appear to be acceptabl .9 (Closed) Follow-up Item 245/85-28-04: ALARA group to develop contingency method to manually follow and review exposure of ongoing jobs when the computerized exposure tracking system fails. The inspector reviewed a memo from the station Health Physics Supervisor to the Unit ALARA coordinators requiring manual tracking of exposure '

for selected priority jobs during computer down-times of two days or

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greater. The inspector discussed this memo with the Unit 1 and 2 ALARA coordinators and verified that additional clerical personnel were available as required to support a manual tracking effor This item is close .10 (Closed) Violation 245/85-15-03: Failure to lock or guard the South Sca an Discharge Volume (SDV) high radiation area. The inspector verified the installation of an automatic locking latch on the south SDV high radiation area door; this completes the licensee commitment as specified in their response to the above Notice of Violation. An additional follow-up item in this area was opened during this inspection; details prov ced in section .11 (Closed) Violation 245/82-24-01, 336/82-26-01: Quality assurance annual audit for transport packages not done. The licensee original-ly responded to this violation by contending that an incorrect cri-terion was cited as the basis of the violation. This violation was subsequently modified to an unresolved item pending additional NRC review and clarification of the correct application of quality as-surance criteria in this area. A review of completed transportation audits f r. subsequent inspections (NRC Report Nos. 245/85-11, 336/85-14; 245/84-04, 336/84-06) indicated the licensee is meeting required audit frequenc .0 Personnel Selection, Qualifications, and Training 4.1 Radiation Protection Personnel The selection, qualification, and training of contractor health physics technicians was reviewed with respect to the following criteric:

ANSI-N18.1, " Selection and Training of Nuclear Power Plant Personnel",

Procedure SHP 4920 " Contracted Health Physics Personnel Training Program".

The licer.see's performance in this area was evaluated by:

review of selected training records and resumes,

discussions with supervisory personne .

Prior to an outage SHP Form 4920-2 is utilized to determine acceptable contractor health physics technician experience. Through

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the use of this form the licensee can determine the quality and quantity of a technician's experience. This practice has resulted in the licensee obtaining an experienced staff of contractor health physics senior technician .

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Within the scope of this review, no violations were identifie .2 Radiation Workers

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The training of radiation workers was reviewed with respect to the following criteria:

10 CFR 19.12 " Instructions to Workers",

General Employee Training Progra The licensee's performance in this area was evaluated by:

discussions with supervisory personnel, discussions with training personnel,

review of selected technician training records,

review of selected lesson plan The inspector examined lesson plans for the General Employee Training Program and found them to be of adequate depth and scop While no "self-monitor" designation exists, radiation workers do receive adequate training in the use of several radiation survey instrument Within the scope of this review, no violations were identifie .0 External Exposure Control The licensee's program for the monitoring and control of personnel exposure was reviewed against the following criteria:

• 10 CFR 20.202, " Personnel Monitoring,"

10 CFR 20.203, " Caution signs, labels, signals and controls,"

Technical Specifications section 6.12. "High Radiation Area,"

• Procedure SHP 4912, " Radiation Work Permit Completion and Flow Control,"

Procedure SHP 4902, " External Radiation Exposure Control and Dosimetry."

Areas reviewed included external dosimetry, the Radiation Work Permit (RWP) system, and High Radiation Area (HRA) Control. The following sec-tions describe the findings in this are .1 External Dosimetry A special NRC dosimetry inspection of the Millstone Station dosimetry handling system and the NUSCO processing laboratory was conducted in August 1985 (combined Inspection Report Nos. 245/85-23, 336/85-28,423/85-47). Inspection effort during this review was concentrated in two areas:

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closecut of open items from the August 1985 inspection;

review of dosimetry assignment for the 1986 Unit 2 fuel pool rerack wor The following material was reviewed by the inspector for the closeout of items generated by the August 1985 inspection:

• Procedure HP 941/2941/3941, " Performance Audits for Personnel Monitoring Equipment,"

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selected results of TLD Audit Performance Tests for 1985 and 1986, e licensee memo No. NEE-80-RA-524, " Reply to Assignment A-18,"

and Nos. NE-85-RA-1138 ard NE-86-RA-223, concerning dosimetry minimum reportable dose,

• neutron pocket dosimeter performance test dat Licensee procedure 941/2941/3941 requires that a monthly performance test be performed on a selected batch of dosimeters. A written in-vestigation is to be completed and filed when unacceptable results are obtained. During the August 1985 dosimetry inspection the in-spector noted that discrepant data was identified during the January and May 1985 dosimeter performance tests; however, the licensee was unable at that time to provide the required investigation reports to the inspector. This was left as an unresolved ite During the current inspection the licensee provided the two outstand-ing dosimetry investigation reports, Nos: NE-85-RA-1007 and NE-85-RA-1217, dated August 16 and October 7, 1985, respectivel Both reports were generated after the completion of the August dosi-metry inspectio The inspector noted that controlling procedure 941/2941/3941 does not set a time requirement for the completion of the dosimetry discrepancy reports, consequently, the lack of time-liness above does not constitute a procedural violation. The in-spector reviewed dosimetry performance data for 1986 and determined discrepant data was now routinely being investigated in a more timely fashion. The licensee stated that a time requirement for the gene-ration of dosimetry discrepancy inv :*igation reports will be added

! to procedure 941/2941/3941. Thfa wil- be reviewed in a subsequent inspection (245/86-12-01, 336 6^ ;2-1 , 423/86-23-01).

i lhe inspector also reviewed dosimetry records for personnel involved l in the Unit 2 spent fuel pool rerack operation. Due to the potential

! - high and non-uniform dose rates inherent in such work, the licensee I assigned multiple whole bcidy and extremity dosimeters for divers involved in this work. The inspector verified, by review of selected exposure records, that appropriate monitoring was provided for se-lected divers and that the highest exposure recorded for each multi-badge set was recorded as the workers exposur _

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5.2 Radiation Work Permits (RWPs)

The licensee's implementation of a Radiation Work Permit (RWP) sys-tem, for control of radiological work activities, was reviewed by the following methods:

interviews of Health Physics (HP) technicians and supervisory personnel, e in-field inspection of RWP compliance during work activities,

• review of the following documentation:

selected RWPs controlling activities in Units 1 and 2

selected radiological survey Within the scope of this review, no violations were identifie Review of the RWP index log indicated that the scope of completed RWPs appeared appropriate in that RWPs were not written to control too wide a range of activities. Radiological controls required by specific RWPs appeared appropriate for the work activities and conditions determined by the associated radiological surveys. The inspectors noted that the Unit 2 spent fuel pool re-racking project, completed during the first two quarters of 1986, appeared well con-trolled. An extensive number of surveys were conducted prior to and during the work to ensure all radiological condit'ons were recognize The inspector also reviewed licensee revisions to procedure 4912,

"RWP completion and Flow Control." These revisions were in response to NRC Inspection No. 245/85-28, in which problems in RWP compliance were noted, due in part to informal RWP changes being made in the fiel The new revision requires HP supervisory approval, with documentation on the official RWP, for all RWP changes. The in-spector reviewed HP briefing attendance sheets and questioned several technicians to verify that personnel were aware of the procedural chang .3 High Radiation Area Control The inspector reviewed the licensee's program for high radiation area control by the following methods:

• tour of plant high radiation area accesses,

- * inspection of the Units 1 and 2 HP key locker and review of key sign-out sheets,

• review of procedure ACP 7.04A, " Station Lock and Key Control,"

• discussion with supervisory personne Previous NRC inspections (245/85-15, 245/86-01, 336/86-01) have documented licensee problems in maintaining adequate control over high radiation areas. The inspector toured radiologically J

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controlled areas in both units to evaluate high radiation area (HRA)

control and did not identify any instances of improper HRA posting or control. The inspector also reviewed the licensee's administrative system for HRA key issue and control and noted the following:

1) There is no formal procedure to describe or control HP issue of HRA keys to work partie Procedure ACP 7.04A, a general procedure describing control for a variety of key types, men-tions HRA keys but does not detail their accountability, issue, or contro ) There is no formal required accountability check of the HP key lockers which house the HRA keys. HP technicians indicated that a check is routinely done; however it is not documente ) A key issue sheet is used to designate the key recipient and time in and out whenever a HRA area key is issued to a worke The inspector verified these sheets were complete and up to dat '

4) A HP technician performs a check of all HRA accesses to ensure they are locked as part of a weekly audit of radiological area The inspector noted, however, that the completed week's audit checklist only indicates that each access was verified closed; it does not indicate when during the week it was checke The licensee indicated that HRA control has been identified internal-ly as a Controlled Routing File item, and that additional actions are required by August 1986 to close out this item. Actions currently under consideration include installation of alarms on all HRA doors and/or self-locking latches, increasing surveillance of HRA doors, or procedural modifications. Additional licensee corrective actions and resolution of their internal Controlled Routing item will be reviewed in a subsequent inspection (245/86-12-02, 336/86-12-02, and 423/86-23-02).

6.0 Internal Exposure Control 6.1 Respiratory Protection

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The licensee's respiratory protection program was reviewed with re-spect to the criteria contained in 10 CFR 20.103 " Exposure of indi-viduals to concentrations of radioactive materials in air in re-stricted areas."

The licensee's performance in this area was evaluated by:

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examination of:

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respirator issuance logs,

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respirator qualification records for selected workers,

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RWP sign-in sheets,

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air sample recoras, interviews of personnel responsible for various aspects of the respiratory protection program and review of their training and qualifications,

reviews of the following procedures:

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SHP 4931 " Selection and Use of Respiratory Protection Equipment,"

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SHP 4932 " Maintenance and QA Program for Respiratory Protection Equipment."

The inspector made the following determinations:

MPC-hours were calculated as required and included in work exposure record *

Personnel responsible for respirator issue, maintenance, and repair were well trained and qualifie Within the scope of this review, no violations were identifie .2 Air Sampling and Bioassay The licensee's program for evaluating airborne radioactivity concen-trations and intakes of radioactive material was evaluated by the following methods:

• review of selected Unit 1 and 2 air-sampling records,

• review of results of routine and post-contamination whole body counts (WBC),

a review of whole body counter calibration record The inspector cross-checked air sample records against selected RWP survey requirements and verified that:

1) sampling was performed as required by the various RWPs, and

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2) air sample times agreed with worker RWP sign-in time During this review of air sample records the inspector noted very few instances of airborne activity in excess of MPC values. The inspec-tor also noted that, for those instances when an airborne situation was detected (for example, in a radiological work tent), air sampling i >

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was performed in adjacent areas to verify the airborne condition had not sprea The inspector reviewed 1985 and 1986 calibration records for the licensee's two whole body counting chairs and verified they were adequate and performed as required. Personnel performing the cali-brations appeared knowledgeable. The inspector also reviewed se-lected personnel contamination incidents and verified that:

1) contaminated personnel were followed up with appropriate whole-body counting and assessment, 2) contaminations did not result from a lack of controls specified on the RWP Within the scope of the above review, no violations were identifie .0 Posting and Labeling of Radiological Areas The licensee's program for posting and labelling of radiological areas was reviewed against the criteria in 10 CFR 20.303, " Caution signs, labels, signals, and controls."

The licensee's performance relative to these criteria was determined from a tour of the controlled areas associated with Units 1 and 2 and from discussion with staff member Within the scope of this review, no violations were identified. All ra-diological areas were found to be appropriately posted as required. The inspector noted that the extent of contaminated areas for both Units has been kept to a minimum. The control of used protective clothing and con-taminated material in Unit I has improved since the last inspection in this area; housekeeping in both units was generally goo .0 Audits of Radiological Activities l

Audits conducted by the Nuclear Review Board (NRB) and the Radiological Assessment Branch (RAB) were reviewed with respect to criteria contained in Technical Specification 6.5, " Review and Audit," Section 6.5.3,

" Nuclear Review Board."

The licensee's performance in this area was evaluated by:

review of selected RAB audits for 1985 and 1986,

review of NRB Audit of RAB, Audit No. A30109, performed 11/8 The inspector determined that the technical specification requirements for audits by the NRB are being satisfied by the licensee in the following manne :

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The RAB conducts monthly audits during normal operations and weekly audits during outage The NRB conducts a quarterly review of RAB audit *

The NRB conducts an audit of the RAB every two year The inspector determined that the RAB and NRB audits were of good tech-nical depth and detail and were being conducted within the stated frequenc Within the scope of this review, no violations were identifie .0 ALARA The inspector discussed ALARA planning efforts in anticipation of the fourth quarter upcoming outage with the Unit 2 ALARA coordinator. The majority of exposure for this outage is anticipated to be expended during steam generator (S/G) eddy-current testing and plugging activities. The ALARA coordinator indicated that a S/G chemical decontamination was plan-ned and included in the outage schedule to lower dose rates in the channel hea Exposure goals for the Unit 2 refueling outage have been developed by the corporate radiological engineering staff. An outage goal of approximately 530 person-rem, and a yearly total goal (outage and operations) of 600 person-rem, have been developed for 1986. This 600 person-rem goal has been set with the intent of achieving INPO target goals (350 to 450 per-son-rem for PWRs) over a three year average from 1986 to 1988. Unit 2 exposure goals for 1987 and 1988 are 100 and 500 person rem, respectively, bringing the average annual exposure goal over the period to 400 per-son-re The inspector determined that ALARA reviews and specific exposure goals have not been developed by the Unit ALARA staff as of the date of this inspection. The Unit 2 ALARA coordinator indicated the ALARA review process is generally started one month prior to the outage (outage scheduled to begin September 20, 1986). The coordinator indicated that specific exposure goals would be developed for each work evolution as part of the ALARA review process. These goals would be compared with the goals generated by the corporate group and the more limiting goal would become the " official goal" for the tas Within the scope of the above review, no violations were identifie .0 Exit Interview The inspector met with licansee representatives (denoted in Section 1) on July 11, 1986. The inspector summarized the purpose, scope, and findings of the inspection. No written material was provided to the license . _ . _ _ _ ___ _ ,- _ . _ _ _ _